The Vodafone Code of Conduct

1 The Vodafone code of ConductDoing what s right22A message from our Chief Executive 3 Why we have a code of Conduct 5 Our Business Principles 7 Speak Up 9 Individual Conduct 11 Security of our people, property and information 11 Avoiding conflicts of interest 13 Gifts and hospitality 15 Travel and expenses 16 Managing our information and documents 16 Compliance with the law 17 Insider dealing 17 Competition laws 18 Bribery and improper payments 19 Anti-money laundering 20 Global sanctions 21 Trade controls 21 Health and safety 22 Contents Financial integrity 23 Committing to contracts and expenditure 24 Operating a responsible supply chain 24 Protecting our brand and other assets 25 Public policy 26 Communications 27 Speaking on behalf of Vodafone 27 Using social media

2 28 Customers 29 Our Privacy Commitments 29 Employees 31 Diversity and inclusion 31 Preventing harassment and bullying 32 Drugs and alcohol 33 Communities and society 34 Environment 35 Key definitions used in this code 36 Trust is fundamental in everything we do .34 Being an admired company is not just about our performance and achievements, it s also about acting in a responsible, ethical and lawful way. A message from our Chief ExecutiveBeing an admired company is not just about our performance and achievements, it s also about acting in a responsible, ethical and lawful way. As one of the world s leading international companies, we need to earn the trust of our customers, colleagues and the communities where we code of Conduct sets out our business principles and how every single person at Vodafone needs to apply these.

3 We call this Doing what s right. I am proud about working for a company that has the highest standards of integrity and which passionately protects its people, assets and reputation. Please take the time to understand our code of Conduct , to Speak Up when you have any concerns and always do what s Colao Vodafone Group Chief Executive OfficerVittorio Colao Vodafone Group Chief Executive OfficerWatch the video56 Why we have a code of ConductTrust is fundamental to everything we what s right means we must always act with integrity to ensure we are trusted by our customers, colleagues , business partners and the communities in which we code of Conduct sets out what we expect from every single person working for and with Vodafone .

4 It also underlines our responsibilities to our people, partners and shareholders. The code of Conduct helps us all make informed decisions and tells us where to go for more is the code of Conduct ?The code of Conduct is our central policy document, outlining the requirements that every single person working for and with Vodafone must comply with, regardless of location. Of course you may also have additional policies you need to adhere to that are specific to your role or your local is the code of Conduct for?Our code of Conduct is for everyone working for and with Vodafone : employees, directors, contractors, subsidiaries, joint ventures and suppliers.

5 We expect our suppliers and business partners to uphold the same standards and to abide by our code of Ethical Purchasing. This can be found on and on the code of Conduct intranet are the consequences of not complying?There are very serious consequences for not complying with our code of Conduct . We may take disciplinary action and even dismiss people where does this mean for me?We expect you to: Behave in an ethical manner, taking pride in your actions and decisions Comply with the principles and rules in our code of Conduct and fulfil your legal and regulatory obligations Understand The Vodafone Way and apply our Business Principles to your work Speak Up if you feel a working practice is not ethical or safe or if it breaches our code of the lawVodafone operates in more than 25 countries.

6 Our code of Conduct cannot cover all of the laws and regulations in all of those countries. Always be familiar with the relevant laws and regulations that apply where you work. If there is a difference between a local legal requirement and our code , apply the most stringent standard. If in any doubt, contact your line manager, Legal, HR, or Compliance you are a line manager, you have an important role in ensuring our code of Conduct is understood and applied by your team. In particular, we expect you to: Be a role model for Doing what s right Ensure your team members are familiar with our code and that they understand it Hold your team members accountable for complying with our you are ever unsure about what to do you should ask yourself: Is it legal?

7 Does it feel right? Am I being fair and honest? Will my action stand the test of time? How will I feel about it afterwards? How would it look on the front page of the newspaper? Could I justify it to my family? If you answer no or I m not sure to any of these questions then you should seek support. You can speak to your line manager or another colleague you trust, they might be able to give you the guidance and advice you need. You can also ask your local Compliance Vodafone WayThe Vodafone Way sets out our core values for how we work so we can be admired by our customers, shareholders, the people we work with and the communities we work Business PrinciplesOur Business Principles are the foundation for how we do business everywhere we operate and are at the heart of our code of Vodafone WayCustomer ObsessedWe are passionate about exceeding customer expectationsWe create and deliver new products.

8 Services and ways of working that delight our customers Immerses self in customer experience Takes personal accountability for the customer experience Looks outside Vodafone to understand customer experience, behaviour and trends Takes risks and pushes what s possible; always looks for innovation Looks outside of Vodafone for ideas and inspiration and acts on these Implements solutions which are simple, impactful and replicable Raises the bar for self and team Delivers lean and cost effective every time Strives to outperform competitors looks beyond internal benchmarksWe drive speed to market. We relentlessly prioritise and pursue the outcomes that matter to our business Makes RAPID business decisions Delivers the right things with urgency Analyses fast, executes fast Sets direction.

9 Generates commitment & engagement Enables performance, balancing task, people & results Builds capacity through growing talent & skills, high performing diverse teams and a lean & effective organisation Acts and communicates with simplicity Prioritises the right things Creates a simple working environment Do what you say you will do Trust others to deliver Support decisions once madeWe make things simple for our customers, partners and colleaguesWe are reliable and transparent to deal with. We deliver for others and trust others to do likewise Collaborates across markets & functions; makes best decision for Vodafone as a whole Influences across the business shapes thinking and impacts others views Values our differences and acts inclusively, communicates and uses best practiceInnovation HungryAmbitious & CompetitiveSpeedSimplicityBe an Admired LeaderTrustWe bring energy and passion to our work and always aim to beat the competitionWe work across Vodafone to achieve the best outcome for customers, employees and shareholdersOne Company, Local Roots8 Our Business PrinciplesIndividual conductWe act with honesty, integrity and fairness in our dealings both internally and externally.

10 We do not tolerate any form of bribery, including improper offers of payments or gifts to or from employees. We avoid any contracts that might lead to, or suggest, a conflict of interest between personal activities and the business. We neither give nor accept hospitality or gifts that might appear to incur an obligation. We pursue mutually beneficial relationships and seek to promote the application of our Business Principles with our business partners and with the lawWe comply with the provisions of all applicable domestic and international laws and appropriate standards and and safetyWe protect the health, safety and wellbeing of our customers, employees.